Privacy and cookies policy

1. Introduction

1.1 We
are committed to safeguarding the privacy of our website visitors and service
users.

1.2 This
policy applies where we are acting as a data controller with respect to the
personal data of our website visitors and service users; in other words, where
we determine the purposes and means of the processing of that personal data.

“Personal
data” is defined in Article 4(1) of the GDPR:

“(1)
‘personal data’ means any information relating to an identified or identifiable
natural person (‘data subject’); an identifiable natural person is one who can
be identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural
person”.

1.3 We
use cookies on our website. Insofar as those cookies are not strictly necessary
for the provision of our website and services, we will ask you to consent to
our use of cookies when you first visit our website.

1.4 In
this policy, “we”, “us” and “our” refer to Anatolijs Levsickis. For more
information about us, see Section 17.

2. How we use your personal data

2.1 In
this Section 2 we have set out:

(a) the
general categories of personal data that we may process;

(b) in
the case of personal data that we did not obtain directly from you, the source
and specific categories of that data;

(c) the
purposes for which we may process personal data; and

(d) the
legal bases of the processing.

2.2 We
may process data about your use of our website and services (“usage data“).
The usage data may include your IP address, geographical location, browser type
and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency
and pattern of your service use. The source of the usage data is our analytics
tracking system. This usage data may be processed [for the purposes of analyzing
the use of the website and services]. The legal basis for this processing is our
legitimate interests, namely [monitoring and improving our website and services.

2.3 We
may process your account data (“account data“). The account
data may include your name and email address. The account data may be processed
for the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.

2.4 We
may process your information included in your personal profile on our website
(“profile data“). The profile data may include your name,
address, telephone number, email address, profile pictures, gender, date of
birth, relationship status, interests and hobbies, educational details and
employment details. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services. The legal basis
for this processing is our legitimate interests, namely the proper
administration of our website and business.

2.5 We
may process your personal data that are provided in the course of the use of
our services (“service data”). The service data may be processed for
the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.

2.6 We
may process information that you post for publication on our website or through
our services (“publication data“). The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.

2.7 We
may process information contained in any enquiry you submit to us regarding services
(“enquiry data“). The enquiry data may be processed for the
purposes of offering, marketing and selling relevant services to you. The legal
basis for this processing is consent.

2.8 We
may process information relating to our customer relationships, including
customer contact information (“customer relationship data“).
The customer relationship data may include your name, your employer, your job
title or role, your contact details, and information contained in
communications between us and you or your employer. The source of the customer
relationship data is [you or your employer. The customer relationship data may
be processed for the purposes of managing our relationships with customers,
communicating with customers, keeping records of those communications and
promoting our products and services to customers. The legal basis for this
processing is our legitimate interests, namely the proper management of our
customer relationships.

2.9 We may process information
relating to transactions, including purchases of services, that you enter into
with us or through our website (“transaction data“). The
transaction data may include your contact details, your card details and the
transaction details. The transaction data may be processed for the purpose of
supplying the purchased goods and services and keeping proper records of those
transactions. The legal basis for this processing is [the performance of a
contract between you and us or taking steps, at your request, to enter into
such a contract and our legitimate interests, namely the proper administration
of our website and business.

2.10 We
may process information that you provide to us for the purpose of subscribing
to our email notifications or newsletters (“notification data“).
The notification data may be processed for the purposes of sending you the
relevant notifications or newsletters. The legal basis for this processing is the
performance of a contract between you and us or taking steps, at your request,
to enter into such a contract.

2.11 We
may process information contained in or relating to any communication that you
send to us (“correspondence data“). The correspondence data
may include the communication content and metadata associated with the communication.
Our website will generate the metadata associated with communications made
using the website contact forms. The correspondence data may be processed for
the purposes of communicating with you and record-keeping. The legal basis for
this processing is our legitimate interests, namely the proper administration
of our website and business and communications with users.

2.12 We
may process your full name, mobile number, email address. This data may include
your name, contact information, password(s) and cardholder data. The source of
this data is our website. This
data may be processed for the proper administration of our website and business
and communications with users. The legal basis for this processing is our
legitimate interests, namely theperformance
of a contract between you and us and/or taking steps, at your request, to enter
into such a contract.

2.13 We
may process any of your personal data identified in this policy where necessary
for the establishment, exercise or defense of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of others.

2.14 We
may process any of your personal data identified in this policy where necessary
for the purposes of obtaining or maintaining insurance coverage, managing
risks, or obtaining professional advice. The legal basis for this processing is
our legitimate interests, namely the proper protection of our business against
risks.

2.15 In
addition to the specific purposes for which we may process your personal data
set out in this Section 2, we may also process any of your personal data where
such processing is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.

2.16 Please
do not supply any other person’s personal data to us, unless we prompt you to
do so.

3. Automated decision-making

3.1 We
will use your personal data for the purposes of automated decision-making in
relation to send any promotion which
may be relevant to you.

3.2 This
automated decision-making will involve sending
any promotion through email.

4. Providing your personal data to others

4.1 We
may disclose your personal data to any member of our group of companies this
means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar
as reasonably necessary for the purposes, and on the legal bases, set out in
this policy.

4.2 We
may disclose your personal data to our insurers or professional advisers insofar
as reasonably necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, obtaining professional advice, or the establishment,
exercise or defense of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.

4.3 Financial
transactions relating to our website and services may be handled by our payment
services providers. We will share transaction data with our payment services
providers only to the extent necessary for the purposes of processing your
payments, refunding such payments and dealing with complaints and queries
relating to such payments and refunds.

4.4 We
may disclose your enquiry data to one or more of those selected third party
suppliers of goods and services identified on our website for the purpose of enabling
them to contact you so that they can offer, market and sell to you relevant
goods and/or services. Each such third party will act as a data controller in
relation to the enquiry data that we supply to it; and upon contacting you,
each such third party will supply to you a copy of its own privacy policy, which
will govern that third party’s use of your personal data.

4.5 In
addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defense of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.

5. Retaining and deleting personal data

5.1 This
Section 5 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.

5.2 Personal
data that we process for any purpose or peramorphosis shall not be kept for
longer than is necessary for that purpose or those purposes.

5.3 We
will retain your personal data as follows:

(a) your
name, contact information, password(s) and cardholder data will be retained for
a minimum period of 3 month and
for a maximum period of 5 years.

5.4 In
some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine the
period of retention based on the following criteria:

(a) the
period of retention of your name, contact information, password(s) and
cardholder data will be determined based on GDPR storage limitation.

Article 5(1)(e) of the GDPR sets out the storage limitation, one of the fundamental rules of the regime:

“Personal
data shall be: … kept in a form which permits identification of data subjects
for no longer than is necessary for the purposes for which the personal data
are processed; personal data may be stored for longer periods insofar as the
personal data will be processed solely for archiving purposes in the public
interest, scientific or historical research purposes or statistical purposes in
accordance with Article 89(1) subject to implementation of the appropriate
technical and organizational measures required by this Regulation in order to
safeguard the rights and freedoms of the data subject … “.

5.5 Notwithstanding
the other provisions of this Section 5, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.

6. Security of personal data

6.1 We
will take appropriate technical and organizational precautions to secure your
personal data and to prevent the loss, misuse or alteration of your personal
data.

6.2 We
will store all your personal data on secure servers, personal computers and
mobile devices, and in secure manual record-keeping systems.

6.3 The
following personal data will be stored by us in encrypted form: your name,
contact information, password(s) and cardholder data.

6.4 Data
relating to your enquiries and financial transactions that is sent from your
web browser to our web server, or from our web server to your web browser, will
be protected using encryption technology.

6.5 You
acknowledge that the transmission of unencrypted (or inadequately encrypted)
data over the internet is inherently insecure, and we cannot guarantee the
security of data sent over the internet.

6.6 You
should ensure that your password is not susceptible to being guessed, whether
by a person or a computer program. You are responsible for keeping the password
you use for accessing our website confidential and we will not ask you for your
password (except when you log in to our website).

7. Amendments

7.1 We
may update this policy from time to time by publishing a new version on our
website.

7.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.

7.3 We
will notify you of changes to this policy by email.

8. Your rights

8.1 In
this Section 8, we have summarized the rights that you have under data protection
law. Some of the rights are complex, and not all of the details have been
included in our summaries. Accordingly, you should read the relevant laws and
guidance from the regulatory authorities for a full explanation of these
rights.

8.2 Your
principal rights under data protection law are:

(a) the
right to access;

(b) the
right to rectification;

(c) the
right to erasure;

(d) the
right to restrict processing;

(e) the
right to object to processing;

(f) the
right to data portability;

(g) the
right to complain to a supervisory authority; and

(h) the
right to withdraw consent.

8.3 You
have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first
copy will be provided free of charge, but additional copies may be subject to a
reasonable fee. You can access your personal data by visiting https://phcarpetcleaning.co.uk/my-profile/
when logged into our website.

8.4 You
have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
personal data about you completed.

8.5 In
some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for exercising
the right of freedom of expression and information; for compliance with a legal
obligation; or for the establishment, exercise or defense of legal claims.

8.6 In
some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer need
the personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defense of legal claims; and you have
objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent;
for the establishment, exercise or defense of legal claims; for the protection
of the rights of another natural or legal person; or for reasons of important
public interest.

8.7 You
have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate
interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment, exercise or defense
of legal claims.

8.8 You
have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.

8.9 You
have the right to object to our processing of your personal data for scientific
or historical research purposes or statistical purposes on grounds relating to
your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.

8.10 To
the extent that the legal basis for our processing of your personal data is:

(a) consent;
or

(b) that
the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a
contract,

and
such processing is carried out by automated means, you have the right to receive
your personal data from us in a structured, commonly used and machine-readable
format. However, this right does not apply where it would adversely affect the
rights and freedoms of others.

8.11 If
you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.

8.12 To
the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.

8.13 You
may exercise any of your rights in relation to your personal data by written
notice to us.

9. Third party websites

9.1 Our
website includes hyperlinks to, and details of, third party websites.

9.2 We
have no control over, and are not responsible for, the privacy policies and
practices of third parties.

10. Personal data of children

10.1 Our
website and services are targeted at persons over the age of 18.

10.2 If
we have reason to believe that we hold personal data of a person under that age
in our databases, we will delete that personal data.

11. Updating information

11.1 Please
let us know if the personal information that we hold about you needs to be
corrected or updated.

12. Acting as a data processor

12.1 In
respect of your name, contact information, password(s) and cardholder data we
do not act as a data controller; instead, we act as a data processor.

12.2 Insofar
as we act as a data processor rather than a data controller, this policy shall
not apply. Our legal obligations as a data processor are instead set out in the
contract between us and the relevant data controller.

13. About cookies

13.1 A
cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.

13.2 Cookies
may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.

13.3 Cookies
do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.

14. Cookies that we use

14.1 We
use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: performance, functionality, targeting);

(b) status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: performance, functionality, targeting);

(c) shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are: performance, functionality, targeting);

(d) personalization – we use cookies to store information about your preferences and to personalize our website for you (cookies used for this purpose are: performance, functionality, targeting);

(e) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: performance, functionality, targeting);

(f) advertising – we use cookies [to help us to display advertisements that will be relevant to you (cookies used for this purpose are: performance, functionality, targeting);

(g) analysis – we use cookies to help us to analyses the use and performance of our website and services (cookies used for this purpose are: performance, functionality, targeting); and

(h) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: performance, functionality, targeting);

15. Cookies used by our service providers

15.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.

15.2 We use Google Analytics to analyses the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: performance, functionality, targeting);

15.3 We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behavior on our website and on other websites across the web using cookies. This behavior tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website). You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996. The relevant cookies are: performance, functionality, targeting;

16. Managing cookies

16.1 Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links: